18-1010 Wednesday “Daily Bugle”

18-1010 Wednesday “Daily Bugle”

Wednesday, 10 October 2018

The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS Welcomes Industry Input for 2019 Annual Conference
  3. DHS/CBP Updates CATAIR Documents
  4. DoD/DSCA Posts Policy Memo 18-31
  5. State/DDTC: (No new postings.)
  6. Treasury Releases Interim Regulations for FIRRMA Pilot Program
  7. EU Continues Targeted Industry Consultation on Draft ICP Guidance Until 15 Nov
  1. The Wall Street Journal: “Treasury Spells Out New Rules on Foreign Deals Involving U.S. Technology”
  2. WCPO: “Affidavit: Chinese Spies Targeted GE Aviation Employee, May Have Stolen Sensitive Documents”
  1. G. Soussan & P. Jeydel: “EU Promotes Export Controls and Sanctions Compliance Programs”
  2. M. Volkov: “A Basic Compliance Requirement: A Contract Management System”
  3. T. Murphy: “Important U.S. Customs Ruling on Determining Country of Origin for Section 301 Purposes”
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: ATF (15 Jan 2016), Customs (19 Sep 2018), DOD/NISPOM (18 May 2016), EAR (26 Sep 2018), FACR/OFAC (29 Jun 2018), FTR (24 Apr 2018), HTSUS (14 Aug 2018), ITAR (4 Oct 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



[No items of interest noted today.]
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OGS_a11. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

* Treasury; RULES;
  – Determination and Temporary Provisions Pertaining to a Pilot Program to Review Certain Transactions Involving Foreign Persons and Critical Technologies; and 
  – Provisions Pertaining to Certain Investments in the United States By Foreign Persons [Publication Dates: 11 Oct 2018.]
* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 11 Oct 2018.]

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Commerce/BIS Welcomes Industry Input for 2019 Annual Conference
Commerce/BIS, 10 Oct 2018.)
form is provided for the exclusive purpose of allowing users to submit topic, content, or format suggestions to BIS for the 2019 Annual Conference, being offered in the Eastern Region.

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DHS/CBP Updates CATAIR Documents 

CSMS# 18-000596, 10 Oct 2018.)

The AE (Entry Summary Create/Update) EDI message Implementation Guide (IG) in the CATAIR “Chapters” tab and the CQ (Cargo Release, Manifest and Entry Release Query) EDI message IG in the “Chapters: Drafts for Future Capabilities” tab have been updated to remove mentions of valid in-bond check digit formats.

Navigate to these documents from the 
CATAIR link.

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Treasury Releases Interim Regulations for FIRRMA Pilot Program

Treasury, 10 Oct 2018.)
The U.S. Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS), today issued temporary regulations to protect critical American technology and intellectual property from potentially harmful foreign acquisitions.  These regulations put to use tools enacted as part of the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), which Congress passed on an overwhelmingly bipartisan basis and that President Trump signed into law in August.
  “We are pleased to implement this first step of the important and bipartisan FIRRMA legislation,” said Treasury Secretary Steven T. Mnuchin. “These temporary regulations address specific risks to U.S. critical technology while informing the development of final regulations that will fully implement FIRRMA.”
FIRRMA authorizes CFIUS to conduct pilot programs to implement provisions in the legislation that did not become effective immediately upon enactment.  Full implementation of FIRRMA will occur no later than February 2020.
The pilot program implements authorities that expand the scope of transactions subject to CFIUS review to include certain non-controlling investments in U.S. businesses involved in critical technologies related to specific industries.  The pilot program also makes effective FIRRMA’s mandatory declarations provision for transactions that fall within the scope of the pilot program.  The pilot program will end no later than the date on which the final FIRRMA regulations are fully implemented.
In addition to the pilot program, Treasury issued temporary regulations that make limited updates to CFIUS’s existing regulations, primarily to implement provisions of FIRRMA that became immediately effective upon its enactment.  This will ensure consistency between CFIUS’s regulations and the statute.  These regulations are effective October 11, 2018.
In accordance with FIRRMA, the pilot program will commence on November 10, 2018, 30 days following publication of the regulations in the Federal Register [tomorrow].
For more information, navigate to the 
fact sheet and text of the regulations (
pilot program regulations and 
updates to existing regulations).

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EU Continues Targeted Industry Consultation on Draft ICP Guidance Until 15 Nov

European Commission, 10 Oct 2018.) 
Effective controls on exports of dual-use goods, software and technology are vital for countering the proliferation of Weapons of Mass Destruction (WMD) and the destabilizing accumulations of conventional weapons. Taking into consideration rapid scientific and technological advancements, the complexity of modern supply chains and the ever growing significance of non-state actors, effective export controls greatly depend on the awareness and active commitment of industry to comply with dual-use export control regulations.
in order to support exporters’ efforts to ensure compliance with EU and national export laws and regulations, the European Commission and EU Member States, under mandate of the Dual-Use Coordination Group, set up a Technical Expert Group entrusted with drafting the attached guidance as a non-binding instrument identifying the core elements that are essential for an effective ICP for dual-use export controls. The draft guidance focuses on the following 7 core elements:
  * Top-level management commitment to compliance
  * Organization structure, responsibilities and resources
  * Training and awareness raising
  * Transaction screening process and procedures
  * Performance review, audits, reporting and corrective actions
  * Record-keeping and documentation
  * Physical and information security

Each core element is further detailed as follows:
  * A section ‘What is expected from dual-use companies?’ describes the objective(s) of each core element; and
  * A section “What are the steps involved?” further specifies the actions and outlines possible solutions for developing or implementing compliance procedures.

Furthermore, the draft guidance contains a set of frequent questions regarding ICPs and provide a list of diversion risk indicators and “red flag” signs about suspicious enquiries or orders.
Considering that ICPs, as industry tools, are of particular interest for exporters, the European Commission and EU Member States have decided to conduct a public survey providing the opportunity for exporters to give feed-back and inputs in relation to the draft guidance.
We would therefore welcome feedback on the proposed seven core elements and the associated draft guidance material attached. The Commission will collect the data from the survey, and make it available to the experts of the Member States so that the Technical Expert Group may proceed with the finalization of the ICP guidance.


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The Wall Street Journal, 10 Oct 2018.) [Excerpts.]
Regulations provide first window into Trump administration’s interpretation of new CFIUS law targeting Chinese investment
Treasury officials Wednesday issued new rules requiring all foreign investors in certain deals involving critical U.S. technology to submit to national security reviews or face fines as high as the value of their proposed transactions.
The new regulations, which implement a 
recently passed law to tighten foreign investment reviews, are more expansive than some had advocated and are likely to bring an unprecedented number of transactions into the purview of the 
Committee on Foreign Investment in the U.S., known as CFIUS.
The Treasury-led interagency committee will now require foreign investors to alert it to all deals giving them access to critical technology across 27 industries — including semiconductors, telecommunications and defense — that the committee believes could threaten U.S. national security and technological superiority, according to CFIUS officials. … 

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WCPO, 9 Oct 2018.) [Excerpts.] 
Chinese spies targeted trade secrets of Cincinnati-based GE Aviation, a global manufacturer of technology used in combat aircraft, helicopters and unmanned aircraft. In a statement to WCPO, GE Aviation said the impact of the espionage was “minimal.” … 
WCPO learned key details of the federal investigation by reading an affidavit filed in February by an FBI agent. The document was supposed to be sealed. However, it was briefly posted on PACER, the website for federal courts, and the 9 On Your Side I-Team discovered it while it was still online. It is no longer available on the website. … 

In the sealed document, the agent disclosed the investigation had concluded “there is probable cause” to believe that the information investigators want to examine “contains evidence of violations of theft of trade secrets, economic espionage and/or export controls.” …

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G. Soussan & P. Jeydel: “EU Promotes Export Controls and Sanctions Compliance Programs”

Steptoe & Johnson LLP, 9 Oct 2018.)
* Authors: Guy Soussan, Esq. 
gsoussan@steptoe.com; and Peter Jeydel, Esq., 
pjeydel@steptoe.com. Both of Steptoe & Johnson LLP.
The European Commission (the Commission) recently issued 
draft guidelines on the core elements that European industry should take into account when implementing internal export controls and sanctions compliance programs.  The guidance – which is legally non-binding – will be finalized upon the results of a public consultation providing the opportunity for EU exporters to comment on its core elements.  Companies can participate by responding to a 
survey until November 15.  It is the intention of the Commission to share the results of this survey with a Technical Expert Group before finalizing its guidance.
Internal compliance programs (ICPs) have long been part of a culture of compliance in the US, but much less so within the European Union.  However, ICPs are increasingly viewed in the EU as a key element for an effective export control system.  While not expressly alluding to ICPs, the EU Dual Use Regulation has encouraged Member States to take into consideration whether a company employs adequate means and procedures for compliance when assessing applications for global export authorizations.  In addition, ICP guidelines have been introduced by some Member States as a tool to better monitor compliance with EU and national export controls.  The EU Dual Use Regulation Recast Proposal formally introduces standardized operational ICPs as part of the assessment in the granting and control of global export authorizations and certain general export authorizations.  In implementing these ICP guidelines, the EU is acting pursuant to the multilateral provisions of the Wassenaar Arrangement that have 
expressed support for ICPs and for this type of regulatory guidance.
The U.S. System 
In the U.S., the export controls and sanctions regulatory agencies have put the implementation and monitoring of ICPs at the top of their agenda for many years.
For example, the US Treasury Department’s Office of Foreign Assets Control (OFAC) lists “the existence, nature and adequacy of a Subject Person’s risk-based OFAC compliance program” as a factor in its Economic Sanctions Enforcement Guidelines in determining the nature and extent of any penalty to impose when an apparent violation is identified, along with being a key element in assessing the remedial response of companies that are the target of enforcement action.  OFAC commonly treats the absence or inadequacy of a company’s compliance program as an “aggravating factor” in its enforcement actions.  OFAC has quite a bit of guidance about compliance programs for various industries on its website, particularly for the financial and insurance industries.
The US Commerce Department’s Bureau of Industry and Security (BIS), responsible for dual-use export controls, has for years had 
compliance program guidelines posted on its website, and similarly considers the adequacy of a company’s compliance program as a factor in guiding its enforcement actions.  Other US government agencies, such as the Department of Justice, also have significant 
online resources in place providing their views on the key elements of an effective compliance program.
The EU’s ICP Guidelines 
The EU’s guidelines provide the following illustrative list of the core elements of an effective ICP structure:
  1. Top-level management commitment to compliance
  2. Organization structure, responsibilities and resources
  3. Training and awareness raising
  4. Transaction screening process and procedures
  5. Performance review, audits, reporting and corrective actions
  6. Recordkeeping and documentation
  7. Physical and information security
The EU guidelines make a number of points that are particularly noteworthy, such as the following:
  1. The guidelines note at the outset that an effective ICP must be tailored to the particularities of the company, which generally calls for a risk assessment to be conducted at the outset of the process of designing an ICP, and to be revisited periodically as the business and regulatory environment change over time.
  2. Companies should ensure that the compliance function is free of conflicts of interest organizationally, such as by making it independent of the sales function, and that it has the power to stop transactions when necessary.
  3. The guidelines note that any transaction screening process should not only focus on the dual use goods classification of the exported item but also on its end-use and whether it is intended for a jurisdiction subject to an EU sanctions regime.
  4. The guidelines also raise the point that a company’s recordkeeping policy should go beyond the documents required by law and should also include proactive documentation of its compliance process, described as documents that “may be in your company’s best interest to maintain.”
  5. In Annex 2, the guidelines provide a list of red flags relating to suspicious enquiries, which are similar to those issued by the US, UK and other authorities.  One particularly noteworthy “red flag,” for example when trading with China or other state-dominated economies, is “the end user is tied to the military, the defense industry or a governmental research body and the stated end use is civilian.” 
Other aspects of the guidelines may call for some elaboration and refinement by the Commission before finalizing this document,  such as the following:
  1. The vague recommendation for screening transactions for “sensitive destinations,” which are described as “not embargoed or sanctioned, but the shipment of (certain) dual-use items thereto can be critical in individual cases, for example because of proliferation or human rights concerns.  Member State governments can implement their own approach on this matter.”  Harmonized EU-wide guidance on which countries or parties raise these concerns would allow companies to act on this in a practical way.  The Commission should also provide guidance about what it means for a company to be “aware” that there is information of concern about a customer’s stated end-use, for example by listing restricted or high-risk end-uses and describing the nature and extent of a company’s due diligence obligation in various circumstances.
  2. While it is positive that the EU guidelines mention physical and information security, the authorities should consider issuing clarifying guidance on the nature and extent of EU companies’ obligations to restrict “intangible” technology transfers, which some view as an enforcement gap in the EU system as compared with the US system.  The reference in these ICP guidelines only to the “removal” of controlled information could raise a question about whether purposeful technology transfers to restricted persons or destinations is problematic under EU law.
  3. It is noteworthy that the EU’s ICP guidance does not go as far as to state that the adequacy or inadequacy of a company’s ICP would be treated as a factor in enforcement decisions, leaving the topic of enforcement to the competency of national level authorities.
While these EU ICP guidelines are a step in the right direction and may be of interest for European exporters, the Commission would benefit from industry input to help make this document more practical and complete.  Without exceeding its authority vis-à-vis national regulators, the Commission should go as far as it can in the final version of these guidelines to provide the latest information on best practices and be as specific and pragmatic as possible in stating what the expectation is of a compliant EU exporter.  We will be looking forward to seeing the next iteration of the ICP guidance.

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M. Volkov: “A Basic Compliance Requirement: A Contract Management System”
Volkov Law Group Blog, 9 Oct 2018. Reprinted by permission.) 
* Author: Michael Volkov, Esq., Volkov Law Group, 
mvolkov@volkovlaw.com, 240-505-1992. 
Assume you are under the influence of a truth serum; does you company have a contract management system?
Some will say yes; I suspect most will say no.  My question is why not?
Lawyers love contracts. Most business people see the value of a contract and will comply with a requirement that a deal will require a contract in order to move forward.  But there is much more to the issue than a lawyer’s desire for a memorialized agreement as a basic requirement for a deal.
Let’s start with a reality test.  Businesses operate under contracts or purchase orders.  Not every business transaction requires a contract.  Most companies have a threshold below which a contract is not required.  Also, when a contract is in place, companies will use purchase orders to conduct individually authorized transactions pursuant to the contract.
A contract management system is imperative for four important purposes:
  (1) To maintain consistency in the formulation and enforcement of contractual relationships;
  (2) To mitigate business risks between the company and a party (e.g. customer, vendor, supplier);
  (3) To protect the company’s culture and mitigate compliance risks through imposition of certifications, representations and warranties, and specific compliance obligations;
  (4) To protect the accuracy of the company’s financial payment and receivables system by verifying the accuracy of payment terms and conditions in accordance with the company’s contractual agreements.
First, a contract management system ensures consistency across the organization when creating business relationships.  Contract templates are critical to ensuring that business negotiations do not lead to changes in corporate policies and procedures.  Of course, changes can be made, if necessary, subject to appropriate approvals.
Second, a company’s use of contracts mitigate business risks by creating specific obligations and remedies should a party fail to perform, provide substandard goods or services, or not meet other terms and conditions.
Third, a company’s consistent use of contracts provides an important mechanism for compliance officers to embed compliance requirements on third parties and customers in order to mitigate compliance risks (e.g. FCPA, sanctions, export controls, money laundering, health and safety).  If the company uses purchase orders for certain transactions, compliance has to make sure that significant compliance provisions are referenced or printed on the backside of a purchase order.
Fourth, and very importantly, a contract management system provides an important check for a company’s receivables and payment functions.  A company has to verify that a payment coming in or going out is the correct amount as specific in a purchase order or in an existing contract. If a company fails to connect these basic two dots – a payment and a purchase order or contract – the company is simply asking for trouble.

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(Source: Author, 10 Oct 2018.) 

U.S. Customs and Border Protection recently published a ruling that every company considering shifting production from China to Mexico (or Canada) as part of a strategy to mitigate the impact of the Section 301 duties should be aware of.  In Headquarters Ruling H300226, CBP concluded that, while the NAFTA Marking Rules (19 C.F.R. Part 102) are used to determine the country of origin of articles imported into the United States from Mexico for marking purposes, the traditional substantial transformation test is used to determine the country of origin of articles for Section 301 duty purposes.  A copy of the ruling is attached here for your reference.
As you will see from the ruling, parts of a motor were imported into Mexico for assembly.  The assembly operation in Mexico was sufficient to satisfy the applicable NAFTA Marking Rule, such that the finished article was considered to a “product of Mexico” for marking purposes.  CBP, however, then went on to say that the traditional substantial transformation test is used for purposes of “antidumping, countervailing, or other safeguard measures[.]”  CBP then applied the traditional substantial transformation test to the facts and concluded that the Mexican assembly operations were not sufficient to confer origin and, therefore, the finished motor imported into the United States was a “product of China” for Section 301 purposes.  So, in short, the product had to be marked to indicate that it was of Mexican origin, but the importer had to pay the Section 301 duty applicable to Chinese-origin articles.
This ruling highlights a few important points.  First, while the traditional substantial transformation test and the NAFTA Marking Rules are meant to embody the same origin principles, they do not always produce the same result due to the different nature of the tests (i.e., the traditional substantial transformation test is subjective; whereas the NAFTA Marking Rules are objective).  Second, for purposes of section 301, the traditional substantial transformation test must be used even if the goods are imported from an FTA-partner country (e.g., Mexico, Canada, Singapore, etc.).  The NAFTA Marking Rules may be helpful to that analysis, but are not determinative.  Finally, CBP is willing to live with this seemingly absurd result (i.e., an article marked “Product of Mexico” being subject to duties applicable to “products of China”).

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Giuseppe Verdi (Giuseppe Fortunino Francesco Verdi; 10 Oct 1813 – 27 Jan 1901; was an Italian opera composer.  Verdi came to dominate the Italian opera scene after the era of Vincenzo Bellini, Gaetano Donizetti, and Gioachino Rossini, whose works significantly influenced him. By his 30s, he had become one of the pre-eminent opera composers in history.)
 – “You may have the universe if I may have Italy.”

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. Are Your Copies of Regulations Up to Date?
(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  The latest amendments to applicable regulations are listed below.
: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War
  – Last Amendment: 15 Jan 2016: 81 FR 2657-2723: Machineguns, Destructive Devices and Certain Other Firearms; Background Checks for Responsible Persons of a Trust or Legal Entity With Respect To Making or Transferring a Firearm. 
: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment: 19 Sep 2018: 83 FR 47283-47284: Extension of Import Restrictions Imposed on Archaeological Material From Cambodia  


  – Last Amendment: 18 May 2016: Change 2
: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and cancelled Supp. 1 to the NISPOM (Summary 

: 15 CFR Subtit. B, Ch. VII, Pts. 730-774

  – Last Amendment: 26 Sep 2018: 83 FR 48532-48537: Addition of Certain Entities to the Entity List, Revision of an Entry on the Entity List and Removal of an Entity From the Entity List

: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders

  – Last Amendment: 29 June 2018: 83 FR 30541-30548: Global Magnitsky Sanctions Regulations; and 83 FR 30539-30541: Removal of the Sudanese Sanctions Regulations and Amendment of the Terrorism List Government Sanctions Regulations 

: 15 CFR Part 30
  – Last Amendment: 24 Apr 2018: 3 FR 17749-17751: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates
  – HTS codes that are not valid for AES are available
  – The latest edition (30 Apr 2018) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR contains all FTR amendments, FTR Letters and Notices, a large Index, and approximately 250 footnotes containing case annotations, practice tips, Census/AES guidance, and explanations of the numerous errors contained in the official text. Subscribers receive revised copies in Microsoft Word every time the FTR is amended. The BAFTR is available by annual subscription from the Full Circle Compliance websiteBITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR. Government employees (including military) and employees of universities are eligible for a 50% discount on both publications at www.FullCircleCompiance.eu.  
, 1 Jan 2018: 19 USC 1202 Annex. (“HTS” and “HTSA” are often seen as abbreviations for the Harmonized Tariff Schedule of the United States Annotated, shortened versions of “HTSUSA”.)
Last Amendment: 14 Aug 2018: Harmonized System Update 1812, containing 27 ABI records and 6 harmonized tariff records.

  – HTS codes for AES are available 
  – HTS codes that are not valid for AES are available 
  – Last Amendment:
4 Oct 2018: 83 FR 50003-50007: Regulatory Reform Revisions to the International Traffic in Arms Regulations.

  – The only available fully updated copy (latest edition: 4 Oct 2018) of the ITAR with all amendments is contained in Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III. The BITAR contains all ITAR amendments to date, plus a large Index, over 800 footnotes containing amendment histories, case annotations, practice tips, DDTC guidance, and explanations of errors in the official ITAR text. Subscribers receive updated copies of the BITAR in Word by email, usually revised within 24 hours after every ITAR amendment.
The BITAR is available by annual subscription from the Full Circle Compliance
. BAFTR subscribers receive a $25 discount on subscriptions to the BITAR, please
contact us
to receive your discount code.

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Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

Review last week’s top Ex/Im stories in “Weekly Highlights of the Daily Bugle Top Stories” published 

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* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, Alex Witt. The Ex/Im Daily Update is emailed every business day to approximately 6,000 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOE/NRC, DOJ/ATF, DoD/DSS, DoD/DTSA, FAR/DFARS, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations.  Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items.

* RIGHTS & RESTRICTIONS: This email contains no proprietary, classified, or export-controlled information. All items are obtained from public sources or are published with permission of private contributors, and may be freely circulated without further permission, provided attribution is given to “The Export/Import Daily Bugle of (date)”. Any further use of contributors’ material, however, must comply with applicable copyright laws.  If you would to submit material for inclusion in the The Export/Import Daily Update (“Daily Bugle”), please find instructions here.

* CAVEAT: The contents of this newsletter cannot be relied upon as legal or expert advice.  Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources.  If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.

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